Concerns on the EUDR implementation increases as the deadline inches closer

The new EU Deforestation Regulation (EUDR) has been pointed out as an important turning point in the global fight against deforestation. Set to take effect on December 30, 2024, this regulation holds significant implications for countries like Brazil, a major exporter of soybean and beef to EU. With the deadline approaching, producers are concerned about their ability to comply to the policy criteria in time. Yet, it is not just about wanting to or having the right technology; there are several uncertainties about which information will be necessary for operators to prove due diligence.

Brazilian stakeholders recently highlighted four major challenges to the effective implementation of the EUDR for soybean and beef supply chains in the country:

1. Legal complianceand documentation: Upstream business actors in producer countries are currently facing the challenge of furnishing the requisite information and documentation to access EU markets. For the actors involved, it is not clear what kind of documentation and proofs will be accepted by national authorities while verifying the links between products and their declared locations of origin. For instance, what level of risk in the supply chain will be considered acceptable for compliance, and what documents can be used as evidence of compliance with the legislation?

2. Data protection: The EUDR requires that traders and operators report the geographic coordinates of the plots of land where commodities were produced, ensuring they are deforestation-free and not associated with illegal practices. As this implies an increased use of monitoring and verification technologies, concerns exist about how to make information across the supply chain transparent while at the same time anonymising it to ensure data security.

3. Role of national platforms: In cases when national databases and platforms providing information relevant to the legislation already exist, would those be recognized as valid sources of evidence for legality? Example of platforms for the Brazilian case are the AgroBrasil+Sustentável and Selo Verde.

4. Potential rehabilitation: Traders and operators who fail to comply with the legislation – for instance, by selling products from non-compliant regions or producers – might be temporarily prohibited from commercialising their products in the EU. However, it is not clear if there are provisions for rehabilitating producers or regions initially excluded from compliance.

The identification of these four major challenges was the result of a collaborative gathering organized by CLEVER researchers from the University of Bonn, alongside the Agricultural Policy Dialogue Brazil-Germany (APD Brasil Alemanha) and the Universidade Federal de Minas Gerais. Bringing together voices from Brazil’s government, private sector, NGOs, and academia, the discussions revolved around the upcoming EUDR implementation. Split into two teams (soybean and beef), participants discussed topics like traceability progress, ongoing hurdles, associated costs, mitigation plans, transition phases, and ensuring that smallholders aren’t left behind due to traceability requirements. Following this participatory approach to pinpoint challenges and solutions, the outcomes were shared at the ‘European Deforestation Regulation (EUDR): Challenges and Traceability Solutions’ Round Table with the German Federal Ministry of Food and Agriculture (BMEL) in Brasília, Brazil, in February 2024.

Fernanda Martinelli (University of Bonn). Photo credit: Tim Bartram.
European Deforestation Regulation (EUDR)
Challenges and Traceability Solutions. Photo credit: Carlos Alberto dos Santos
CLEVER Project Coordinator Jan Börner (University of Bonn). Photo credit: Carlos Alberto dos Santos
European Deforestation Regulation (EUDR)
Challenges and Traceability Solutions. Photo credit: Carlos Alberto dos Santos.
European Deforestation Regulation (EUDR) Challenges and Traceability Solutions. Photo credit: Carlos Alberto dos Santos.

Written by Fernanda Martinelli / University of Bonn.